Object
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200276
Received: 24/01/2025
Respondent: Abbey Properties Cambridgeshire Limited
This contribution is inappropriate in all regards. There can be no direct correlation between new development and burials: for instance it is very possible that burials would take place in other locations - i.e. alongside other family members. The requirement to deliver new burial grounds within large new strategic locations is supported. Adding yet a further contribution to small housing schemes is inappropriate. The correlation between the figures is not clear particularly given the likely percentage of cremations.
This contribution is inappropriate in all regards. There can be no direct correlation between new development and burials: for instance it is very possible that burials would take place in other locations - i.e. alongside other family members. The requirement to deliver new burial grounds within large new strategic locations is supported. Adding yet a further contribution to small housing schemes is inappropriate. The correlation between the figures is not clear particularly given the likely percentage of cremations.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200289
Received: 24/01/2025
Respondent: Savills UK
Please see attached document for representations on behalf of Pigeon.
Please see attached document for representations on behalf of Pigeon.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200318
Received: 24/01/2025
Respondent: Home Builders Federation
The SPD suggests that planning obligations will be sought from residential development. It suggests that proposals for over 200 dwellings should be accompanied by assessments of need and strategies regarding how the need will be addressed. It also provides a contribution to cost per dwelling based on number of bedrooms, these range from £139.26 for a 1-bed dwelling to £369.10 for a 4+bed dwelling.
The HBF is concerned that the viability of these costs has not be considered, and whilst the South Cambridgeshire Local Plan includes a reference to burial space the same cannot be said for Cambridge Local Plan, therefore this policy requirement has not been test and examined in public as required by the NPPF and PPG.
This section of the SPD is based on Policy 85 of the Cambridge Local Plan and Policy SC/4 of the South Cambridgeshire Local Plan. The SPD suggests that planning obligations will be sought from residential development. It suggests that proposals for over 200 dwellings should be accompanied by assessments of need and strategies regarding how the need will be addressed. It also provides a contribution to cost per dwelling based on number of bedrooms, these range from £139.26 for a 1-bed dwelling to £369.10 for a 4+bed dwelling.
The HBF is concerned that the viability of these costs has not be considered, and whilst the South Cambridgeshire Local Plan includes a reference to burial space the same cannot be said for Cambridge Local Plan, therefore this policy requirement has not been test and examined in public as required by the NPPF and PPG.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200361
Received: 24/01/2025
Respondent: Vistry Strategic Land and Major Projects
Agent: Turley
The SPD sets out the amount of burial space per dwelling:
While there is some evidence presented to support this, the Constitutional Affairs Select Committee Eighth Report 2006 cited is somewhat dated and the Councils should consider whether there is any up-to-date evidence to support the figures stated. In addition, there is no evidence to support the stated statistic that each hectare of a cemetery can accommodate around 3000 burial plots. Therefore, while we do not object to the principle of the obligation itself, the amount of space identified needs to be evidenced.
In terms of contributions, the SPD proposes that smaller developments should provide a contribution where a need is identified in consultation with the Parish Council. Paragraph 13.11 states:
The cost of acquiring new land for burials is around £240,000 per hectare and the cost of preparing that land for burials is £100,000 per hectare meaning a contribution of £34 per m2 of burial space or £113.22 per each plot.
The Councils should clarify the evidence underpinning these estimated costs and whether there is a cost difference between the two authority areas.
On behalf our client Vistry Strategic Land, please find attached our representations to the current Planning Obligations SPD consultation.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200401
Received: 24/01/2025
Respondent: U+I (Cambridge) Limited and Cambridge 4 LLP
Agent: Carter Jonas
Regarding Paragraph 13.7 U+I (Cambridge)
Limited and Cambridge 4 LLP would like to query how the threshold of 200 dwellings was arrived as it seems low.
Paragraph 13.11 contains the burial sites contribution by dwellings size. U+I (Cambridge) Limited and Cambridge 4 LLP query how these contributions by dwelling size have been formulated and what evidence was used to calculate the cost. It is also unclear if the need has been fully evidenced as required by Regulation 122.
On behalf of our client, U+I (Cambridge) Limited and Cambridge 4 LLP, please find attached our formal Representations to the Draft Greater Cambridge Planning Obligations Supplementary Planning Document.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200460
Received: 23/01/2025
Respondent: Hill Residential Ltd (Hill)
Agent: Tor & Co
The South Cambridgeshire Local Plan (2018) Policy SC/4 ‘Meeting Community Needs’ includes provision for burials in the list of services and facilities to be provided, however there is no table or level of contributions / requirements set out within policy. In contrast, the draft SPD sets out requirements and contributions which were not tested as part of the Local Plan process. This could undermine the deliverability of the Local Plan, potentially impacting the ability for allocated sites to deliver policy compliant viable schemes, in conflict with paragraph 34 of the NPPF.
On behalf of Hill Residential Ltd (Hill), we have set out in the attached letter a response to the following draft Greater Cambridge Planning Obligations SPD.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200461
Received: 23/01/2025
Respondent: Hill Residential Ltd (Hill)
Agent: Tor & Co
Paragraph 13.8- It identifies that 1ha of cemetery can accommodate around 3,000 burial plots (3.33m2 required per plot). The SPD is not clear if one plot equates to one individual or if there could feasibly be several individuals within the one plot (cremations assumed). The table (following paragraph 13.9) setting out the burial space required per dwelling size, appears to be referencing the average occupancy per dwelling size (as set out in Appendix A), thus suggesting that 1 person requires 1m2. This does not seem correct in the context of the information presented in paragraphs 13.8 and 13.11 and the table following paragraph 13.11 which sets out the contributions by dwellings size.
On behalf of Hill Residential Ltd (Hill), we have set out in the attached letter a response to the following draft Greater Cambridge Planning Obligations SPD.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200462
Received: 23/01/2025
Respondent: Hill Residential Ltd (Hill)
Agent: Tor & Co
South Cambridgeshire Local Plan (2018) Policy SC/4, that in reflecting Planning Practice Guidance, the Council does not seek tariff style Section 106 contributions for general off site infrastructure improvements from sites under 10 dwellings (and which have a combined gross floor space of no more than 1,000m2). Many of the obligations set out in the draft SPD that relate to general off site infrastructure improvements set out, in some instances, that obligations will be sought from all residential developments, regardless of size. This should be reviewed and amended in line with the adopted local plan and the PPG.
On behalf of Hill Residential Ltd (Hill), we have set out in the attached letter a response to the following draft Greater Cambridge Planning Obligations SPD.
Comment
Draft Greater Cambridge Planning Obligations Supplementary Planning Document Consultation
Representation ID: 200578
Received: 24/01/2025
Respondent: Carter Jonas
Number of people: 6
Regarding Paragraph 13.7, it is queried how the threshold of 200 dwellings was arrived at as it seems low.
In Paragraph 13.11, it provides the burial sites contributions by dwellings size, it is queried how these dwellings by size have been formulated and what evidence was used to calculate the cost. This needs to be fully evidenced as required by Regulation 122.
Dear Sir / Madam,
Here are some representations in respect of the above reference consultation draft SPD’s submitted on behalf of the following named clients:
• TLC Group
• Rockley Dene Homes Ltd
• The Fellows House Ltd
• SPK Residential Cambridge Ltd
• London Inn Hotels (Cambridge) Ltd
Yours faithfully
Colin Brown
Colin Brown MRTPI
Partner, Head of Planning & Development